California’s New Packaging Compliance Rules
May 26, 2026 | 5 min read
A practical overview of the packaging compliance program most wineries have not heard about yet. First step due June 1st!
Written by Jeanette Tan | Photo by Shutterstock
The State of California passed new compliance regulations on May 1st, and they now expect producers to begin submitting paperwork June 1st. While many details are still evolving, this appears to be a real new compliance program wineries should understand.
Disclaimer: This is not legal advice. There has been virtually no information or discussion in the wine industry. Please refer to the links for the official details. As usual, please discuss this with your compliance or legal advisors.
The law is “Plastic Pollution Prevention and Packaging Producer Responsibility Act” and is included in California’s new packaging law under SB 54. The short name is “CalRecycle EPR Program”
This is not the same thing as the CRV bottle deposit program, even though both are managed through CalRecycle.
Be prepared to learn more acronyms.
Many details have not been determined but this is the timeline:
June 1st, 2026 – Deadline to register and to apply for an exemption (more below)
June through December 2026 – Reporting systems and packaging data collection to begin
Jan 1st, 2027 – Begin payment of fees
Are you an EPR Producer?
You are likely an EPR Producer is you sell wine under your own label in California (bottled in California or shipped into California).
Are you an Exempt EPR Small Producer?
You likely qualify for the EPR Small Producer exemption if you made less than $1 Million in GROSS California sales last year. The regulations state “gross California sales,” which suggests this may include tasting fees, merchandise, events, and other California revenue — not just wine sales.
NOTE: Exempt does not mean ignore this.
Next steps for EPR Small Producers
Register with CalRecycle.
Access the PEPRS portal (this is a new portal).
Formally apply for the small producer exemption.
Next steps for all other EPR Producers
Join the Circular Action Alliance (the organization authorized to manage this program in California). The CAA will interface and transfer your info to CalRecycle.
Submit packaging and supply data.
In 2027, pay fees through their program.
Note: there is a third option shown on the CalRecycle as “Independent Producer” for “Self-Reporting”. This is for the mega wineries.
Final to-dos for all EPR Producers
Moving forward, you will need to maintain records for all of your packaging-related data. This is the real operational headache.
Details for all packaging components:
Glass, cans, bag-in-box, etc
Corks, screwcaps, closures, etc
Capsules, shrink sleeves, etc
Cartons, dividers, shippers, etc
Tape, inserts, pallet wrap, etc
Material composition for each of the above
Packaging weights for each of the above
Units sold into California for each of the above
Recyclability information for each of the above
Discuss with your team how to standardize your packaging specs and how to consolidate your packaging records. (I have seen your records on these details and they are not very good….)
Acronym Recap
EPR - Extended Producer Responsibility, A system where producers become financially responsible for the recycling and disposal of packaging materials.
SB 54 - California Senate Bill 54, California’s packaging and plastic waste law that created the new EPR program.
CalRecycle - California Department of Resources Recycling and Recovery, The California agency administering the EPR and CRV programs.
CRV - California Redemption Value, California’s bottle deposit system for beverage containers
PEPRS - Packaging Extended Producer Responsibility System, California’s online portal for EPR registration, reporting, and exemption filing
PRO - Producer Responsibility Organization, An organization that manages compliance and recycling obligations on behalf of producers.
CAA - Circular Action Alliance, The approved PRO currently managing California’s packaging EPR system.
Please forward this post to your winery friends. Almost nobody in the industry seems to be talking about this yet, and the filing deadline is looming.
